GDPR Policy

Commercial and Business Lawyers Ltd
1 Levens Road, Hazel Grove
Cheshire. SK7 5DL

t   0333 1234 344
e  bd@cbl.law
w  www.cbl.law

 

Introduction

Commercial and Business Lawyers Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will tell you how we look after your personal data when you visit our website,   www.cbl.law or use our services and also tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Commercial and Business Lawyers Ltd collects and processes your personal data when you interact with us, including any data you may provide through our website, when you meet with us or contact us through phone, post or email regarding our services.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Commercial and Business Lawyers Ltd is the controller and is responsible for your personal data that you share with us at any given time.

Our data privacy manager is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to the right to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Commercial and Business Lawyers Limited

Postal address: 1 Levens Road, Hazel Grove, Cheshire, SK7 5DL

Phone number: (+44) (0)333 1234 344

Data privacy manager: Mr Brian Drewitt

Email address: bd@cbl.law

You have the right to make a complaint relating to your personal data at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We may make changes to our Privacy Notice from time to time. The current copy is available on our website or can be requested from us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our website and emails may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (also known as anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, passport number, driving licence number and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details and unique tax reference numbers.

Transaction Data includes details about payments to and from you and other details of the cost services that amounts from using Commercial and Business Lawyers Ltd.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes history of services provided to you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not routinely collect any Special Categories of Personal Data about you, this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. On occasion we may process data about criminal offences. As solicitors we are officers of the court and process any such information in this capacity.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel an arranged service you have with us, although if this occurs, we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

Enquire about or engage our services;

subscribe to our service or publications by email or on our website;

request marketing to be sent to you;

give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns (however this is not a regular occurrence). We collect this personal data by using, server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

analytics providers such as Google based outside the EU;

search information providers such as Searchflow,  inside the EU.

Credit reference agencies carrying out automated profiling, confirm your identity and provide a credit check

Contact, Financial and Transaction Data from providers of technical, payment and delivery services banks based inside the EU.

Identity and Contact Data from publicly availably sources such as Companies House, HM Land Registry, the Intellectual Property Office, the Information Commissioner and the Electoral Register based inside the EU.

Contact and Identity data from other professional advisers who contact us requesting our services on your behalf or who represent other parties involved in your matter.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct communications to you via email or text message. You have the right to withdraw consent to communication at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new client

(a) Identity

(b) Contact

Performance of a contract with you

To confirm your identity including an automated credit check

(a) Identity

(b) Contact

(c) Financial

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) To comply with a legal and regulatory obligation (anti-money laundering requirements)

To provide legal services to you including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Advising you of changes to the law

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how our clients use our services)

To administer and protect our business and this website including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.

(b) Necessary to comply with a legal obligation

To deliver relevant website content to you and measure or understand the effectiveness of the services we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests to study how clients use our services, to develop them, to grow our business.

To use data analytics to improve our website, alongside with client relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests to define types of clients for our services, to keep our website updated and relevant, to develop our business.

To make suggestions and recommendations to you about services that may be of interest to you such as alternative dispute resolution

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests to develop our services and grow our business ensuring our clients have the best experience with Commercial and Business Lawyers

Marketing

We strive to provide you with choices regarding certain personal data uses. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide the best way to satisfy your needs as a client with Commercial and Business Lawyers Ltd.

You will receive specific communications from us if you have requested information from us or are using or have used the services we offer.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside Commercial and Business Lawyers Ltd for any such purposes.

Opting out

You can ask us or third parties to stop sending you marketing communications at any time or adjust your preferences as a client by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service experiences, registration of any kind, or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Service providers acting as processors such IT service providers based in the United Kingdom who provide IT and system administration services.

Service providers acting as processors such software service providers based in the United States who provide IT services such as Microsoft (whose privacy policy can be accessed at  https://privacy.microsoft.com/en-GB/) and Google (whose privacy policy can be accessed at https://policies.google.com/privacy) who adhere to the EU-US Privacy Shield Framework which provides a mechanism for complying with data protection requirements when transferring personal data from the EU to the US.

Professional advisers including other lawyers, bankers, auditors and insurers based within the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

HM Land Registry, Information Commissioner’s Office, Intellectual Property Office, Companies House, HM Courts and Tribunal Services and any other public office based in the United Kingdom.

Fraud Prevention Agencies

Credit reference agencies

If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA) other than as specifically mentioned above or on your instructions as part of our engagement by you.

Where external third parties are based outside the European Economic Area (EEA) their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data in the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business or interest, need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data for six years after they cease being clients for tax purposes. Depending on the type of transaction and the documents involved sometimes we may need to retain your data for up to 12 years.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.